R v Wilson [1984] AC 242

The defendant, a motorist, got into an argument and punched a pedestrian.

Lord Roskill stated:

"grievous bodily harm may be inflicted … either where the accused has directly and violently "inflicted" it by assaulting the victim, or where the accused has "inflicted" it by doing something, intentionally, which, although it is not itself a direct application of force to the body of the victim, does directly result in force being applied violently to the body of the victim, so that he suffers grievous bodily harm."

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